UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF LOUISIANA

IN THE MATTER OF: NO: 07-11862A

RON & LARHONDA WILSON

DEBTOR CHAPTER 13

RESPONSE TO MOTION TO LIFT

NOW INTO COURT, comes above Debtor(s), appearing through undersigned

counsel, answering OPTION ONE’S MOTION TO LIFT as follows:

On information and belief debtor is completely current.

Debtor has made each and every payment:

Western Union October and November

check December
Certified mail

Cashiers + personal check January

Certified mail

Cashiers Feburary
Certified mail

Personal check March

Certifed mail

It does not appear that Mover has cashed the personal checks. However, it is outside the

control of debtor to force mover to deposit check which are timely submitted. On
information and belief these personal checks, Western Union payments and/or cashiers

checks have not been returned to debtors and remain in the possession of mover.

WHEREFORE, above debtor prays that this Response be deemed sufficient to

deny/consent Chase’s Motion to Lift and all other relief the court may grant.

In the event movers lift stay has been filed in error debtor would request fees and

costs for the filing of this motion.

Respectfully submitted,
HARRINGTON & MYERS
/S/ELISABETH HARRINGTON
ELISABETH HARRINGTON (20852)
PO BOX 13127
NEW ORLEANS, LA 70185
504-861-0550
 UNITED STATES BANKRUPTCY COURT
EASTERN DISTRICT OF LOUISIANA

IN THE MATTER OF: NO: 07-11862A

RON & LARHONDA WILSON

DEBTOR CHAPTER 13

CERTIFICATE OF SERVICE

I do hereby certify that a copy of the foregoing RESPONSE TO Option’s

MOTION TO LIFT and any applicable Hearing has been served upon The

Trustee and any attached creditors Electronically and/or by facsimile and/or by

placing same in the United States Mail, First Class, postage prepaid and properly

addressed, on 3/31/08.

S.J. Beaulieu, Jr.

433 Metairie Rd., Suite 307
Metairie, La.70005

Clay Wirtz
Electronically

HARRINGTON & MYERS

/s/Elisabeth Harrington
PO BOX 13127
NEW ORLEANS LA. 70185